ProfessorBainbridge.com

Yours truly cited in a post-Kokesh case

In U.S. v. Bank, 378 F. Supp. 3d 451 (E.D. Va. 2019), the court explained that:

This matter is before the Court on Defendant Daryl G. Bank's (“Defendant” or “Bank”) Motion to Dismiss for Double Jeopardy Violation. Def.'s Mot., ECF No. 139. Defendant moves to dismiss the pending indictment against him in light of the United States Supreme Court's decision in Kokesh v. SEC, ––– U.S. ––––, 137 S. Ct. 1635, 198 L.Ed.2d 86 (2017).

The indictment charges various violations of the securities laws. The court further explained that:

Defendant claims that the 2017 Supreme Court decision in Kokesh, which declared SEC disgorgement a penalty, bars pursuit of the instant criminal action under the Double Jeopardy Clause of the Fifth Amendment because Defendant has already been punished for some of the activity with which he is charged. The Government replied on December 11, 2018, arguing ... that he cannot claim Double Jeopardy because he only received a civil punishment [in the prior SEC action].

In a footnote to the section of the opinion addressing that argument, the court observed that:

Kokesh has sparked a debate about whether district courts have the authority at all to impose disgorgement because the Supreme Court appeared to question such authority. See Kokesh, 137 S. Ct. at 1642 n.3 (stating that the court offered “[n]o opinion on whether courts possess authority to order disgorgement in SEC proceedings”); Donna M. Nagy, The Statutory Authority for Court-Ordered Disgorgement in SEC Enforcement Actions, 71 S.M.U. L. Rev. 896, 898 (2018) (explaining how, at oral argument for Kokesh, the Justices questioned the authority to order disgorgement and invited challenges to it by disclaiming, in a footnote of the opinion, that it was not deciding the issue). Those arguing there is no authority for disgorgement suggest that, now that disgorgement has been declared a penalty, it can no longer be within a district court's equitable authority because a court cannot impose penalties when acting in equity. See, e.g., Stephen M. Bainbridge, Kokesh Footnote Three Notwithstanding: The Future of the Disgorgement Penalty in SEC Cases, 56 Wash. U. J.L. & Pol'y 17, 21-22 (2018). Those arguing that there is authority posit that just because disgorgement is a penalty for one purpose does not mean it is a penalty for all purposes, and that Congress has expressly recognized a court's power to order disgorgement. See, e.g., Nagy, supra, at 901-903. In March of 2019, a bill was introduced in the Senate that would resolve this debate by amending 15 U.S.C. § 78u(d) to expressly grant district courts the authority to order disgorgement. Securities Fraud Enforcement and Investor Compensation Act of 2019, S.799, 116th Cong. (2019).

That said, a district court's authority to order disgorgement is not at issue here. Accordingly, the Court assumes, for the purposes of this motion only, that district courts necessarily have the authority to order disgorgement under the equitable authority granted to them by one of the statutes discussed above. See 15 U.S.C. §§ 77t(b), 77v(a), 78aa, 78u(d) (1).

 

Yours truly cited in a case involving right of refusal transfer restrictions in close corporations

The Westlaw headnote in Minority Dewey v. Bechthold, 18-CV-1739-JPS, 2019 WL 2193865 (E.D. Wis. May 21, 2019), explains:

Background: Minority shareholders of several closely held corporations and various related trusts and beneficiaries brought action against majority shareholders and corporations, alleging fraud and violations of Wisconsin state law in connection with their rights as shareholders, and seeking declaratory judgment that creation of transfer restriction on shares gave majority shareholders the ability to manipulate the books to force minority stockholders to sell their shares to the controllers at an artificially-depressed price, which rendered right-of-refusal provision in transfer restriction unreasonable and unenforceable as a matter of law. Defendants moved to dismiss for failure to state a claim. ...

Holdings: The District Court, J.P. Stadtmueller, J., held that: ... 

2 transfer restriction was not invalid, unreasonable, or unenforceable;

In support of that holding, the Court explained that:

Wis. Stat. § 180.0627(4)(a) permits right-of-refusal transfer restrictions that “obligate the shareholder...first to offer the corporation or other persons, whether separately, consecutively or simultaneously, an opportunity to acquire the restricted shares.” Most courts in Wisconsin (and throughout the country) uphold these restrictions if they are “reasonable” and if the party against whom the restriction is asserted had notice of the restriction. Allen v. Biltmore Tissue Corp., 2 N.Y.2d 534, 161 N.Y.S.2d 418, 141 N.E.2d 812, 816 (N.Y. Ct. App. 1957); Bruns v. Rennebohm Drug Stores, 151 Wis.2d 88, 442 N.W.2d 591, 596 (Wis. Ct. App. 1989) (acknowledging that “close corporations have a special need to control the number and character of shareholders”); Casper v. Kalt-Zimmers Mfg. Co., 159 Wis. 517, 149 N.W. 754, 756 (Wis. 1914) (noting that right-of-refusal restrictions reflect sound business policy).2 However, “if the by-law under consideration were to be construed as rendering the sale of the stock impossible to anyone except to the corporation at whatever price it wished to pay, we would, of course, strike it down as illegal.” Allen, 161 N.Y.S.2d 418, 141 N.E.2d at 816. Although Wisconsin courts routinely uphold these types of provisions, some courts have held that rights-of-refusal should be narrowly construed. Frandsen v. Jensen-Sundquist Agency, Inc., 802 F.2d 941, 945–46 (7th Cir. 1986) (applying Wisconsin law and holding that a right-of-refusal is not triggered by a merger). Finally, it is worth noting that there is no legally mandated option price. Rather, the option price is set at the discretion of the corporation. See Nichols Constr. Corp. v. St. Clair, 708 F. Supp. 768, 771 (M.D. La. 1989), aff'd mem., 898 F.2d 150 (5th Cir. 1990) (holding that “the mere failure to pay ‘fair value’ for stock under a stock redemption agreement” is not “fraud or breach of fiduciary duty.”); F.B.I. Farms, Inc. v. Moore, 798 N.E.2d 440, 448 (Ind. 2003) (“to the extent that restriction devalues the shares in the hands of any individual shareholder by reason of lack of transferability, it is the result of the bargain they struck”); see also Stephen M. Bainbridge, Corporate Law, § 14.2 (3d ed. 2015) (explaining the aforesaid and noting that, where a right-of-refusal provision is in place, even option prices set at fair market value will be dramatically discounted by potential third party purchasers to account for the bargain's low likelihood of success).

Yours truly cited in a case involving, of all things, the estate of Phyllis Schlafly

In a dispute over who is entitled to collect the proceeds from two life insurance policies taken out on the late Phyllis Schlafly by defendant Eagle Forum, a non-profit membership organization incorporated under the laws of Illinois, the court held that:

There is no merit in Andrew’s argument that members of Eagle Forum own Eagle Forum’s corporate property, i.e., the Policies. It is well-settled that members or shareholders of a corporation have no right to use or possess corporate property. Stephen M. Bainbridge, The Board of Directors as Nexus of Contracts, 88 Iowa L. Rev. 1, 3 n.5, 13 n.50 (2002) (“[O]wnership is not a particularly useful concept in the corporate context.... [S]hareholders have no right to use or possess corporate property.” (citing cases) )

Schlafly v. Eagle Forum, CV172522ESSCM, 2019 WL 2498768, at *5 n.4 (D.N.J. June 17, 2019). Andrew is a member of the defendant non-profit corporation and advanced various claims that the corporation's board of directors was misusing the proceeds. In one of his claims, "Andrew seeks to direct the insurance proceeds to the benefit of the class of Eagle Forum members into a constructive trust because the members of Eagle Forum, not Eagle Forum itself, are the rightful beneficiaries of the Policies."

in reply, the Court rued that "The plain language of the John Hancock and Lincoln National Policies are subject to one interpretation only: that Eagle Forum, not its membership, is the owner and primary beneficiary on the Policies." It then dropped the footnote to dismiss the alternative argument.

My article, Enhanced Accountability: The Catholic Church’s Unfinished Business, has been posted to SSRN

Enhanced Accountability: The Catholic Church’s Unfinished Business (July 17, 2019). 53 University of San Francisco Law Review 165 (2019); UCLA School of Law, Public Law Research Paper No. 19-22. Available at SSRN: https://papers.ssrn.com/sol3/papers.cfm?abstract_id=3421795

Abstract: Events of the Summer 2018 brought the long running sexual abuse crisis in the Roman Catholic Church back onto the front pages, highlighting the role of diocesan bishops in covering up the scandal and enabling abusers. In response to these developments, the Church is again considering reforms to protect victims and punish abusers and enablers. This article proposes that the Church create a system for laity to anonymously report allegations, enact strong protections for whistleblowers, and impose a mandatory whistleblowing requirement on priests. As a 2018 Pennsylvania grand jury report demonstrates, however, the laity was reporting the abuse to the Church but the hierarchy buried those reports in secret files. The ultimate problem thus is not so much the lack of reporting, as it was the lack of action after the report. Accordingly, the article’s principal proposal is the creation of both diocesan and national disciplinary bodies led by expert lay members as the ultimate authorities in sex abuse cases. The proposal draws an analogy between these bodies and corporate audit committees and argues that a number of aspects of how audit committees function can be usefully adapted to the proposed review bodies.

Keywords: Roman Catholic Church, corporate governance, compliance, law and economics, credence good

Sadly, the article was finalized before the USCCB's June meeting. In anticipation of the proposals likely to be considered at the June meeting, the article was revised at the last minute to critique such ideas as the metropolitan model. I was able to get that critique into the public domain by posting a revised working draft of this paper to SSRN and by writing several short essays for Public Discourse. Although the article's criticisms did not prevail, the USCCB's June 2019 reforms have a three-year sunset provision. I hope my article will provide guidance for that review.

New SSRN Posting--"Bob Cochran on Law and Lawyering--A Catholic Perspective"

Available at https://papers.ssrn.com/sol3/papers.cfm?abstract_id=3421790

Abstract

This essay is a contribution to a festschrift honoring Pepperdine law professor Robert Cochran. In addition to his many other professional accomplishments, Professor Cochran is a leading figure in the study of Law and Christianity.

One strain of Law and Christianity scholarship focuses on normative critiques of substantive legal issues based on Christian theology. In other words, it seeks to make the civil law more moral; i.e., to conform Man’s Law to God’s Law. A second strain seeks to help lawyers deal with the difficulties inherent in being a Christian and a lawyer. As Cochran has put it, one might ask “whether there is a connection between religious faith and what ordinary lawyers do in ordinary law offices on ordinary Wednesday afternoons.”

Cochran’s work has intersected both possibilities. In Part I of this Article, I tackle his analysis of the extent to which we should strive to harmonize God’s and Man’s Law. In Part II, I turn to Cochran’s analysis of the Christian lawyer’s vocation. In both parts, I come at his work from the perspective of a Roman Catholic called upon to give religious assent to both Christian scripture and, where I differ from Cochran, the Church’s Magisterium.

Keywords: law, jurisprudence, law and religion

Apparently, I'm the Avis of corporate law professors

Readers of a certain age will recall Avis Rent-a-Car's slogan "We're #2. We try harder." Apropos of which I refer you to Robert Anderson's post: Citation Engagement Counts - The Case of Corporate Law Scholars:

Citation counts (and other types of citation-based metrics) are increasing in importance in the legal academy. Some people like the objectivity of these measures and others lament their failure to capture important non-quantifiable aspects of scholarly influence.

One of the most influential citation count rankings in the legal academy is the Sisk-Leiter approach that Greg Sisk updates every three years. Last fall when the new Sisk et al. citation count study came out I proposed a small change to the Sisk-Leiter method that would attempt to measure engagement, defined as citing a particular article more than once. This was designed to address the "throwaway" citation problem that critics of citation counts have raised--that some papers may receive a large number of perfunctory "one off" citations that are less meaningful as a measure of scholarly influence.

I decided to experiment with this using the most highly cited scholars in my field, corporate law and securities regulation, using the citation count rankings as compiled by Brian Leiter. ...

Although the two measures do produce slightly different ordinal rankings, the differences are not significant at least for this small group of 20 scholars. Professor Stephen Bainbridge moves up from third place to second place and Professor Donald Langevoort moves up from 7th place to 5th place.

Bainbridge throws hat into Delaware ring

Being far too modest to put my name forward, I trust that some of my friends in the corporate law academy (and perhaps even some of my foes) will step up to the plate and encourage Delaware to consider, well, yours truly. https://t.co/uw2dlVsqW8

— Professor Bainbridge (@ProfBainbridge) July 8, 2019

No brag, just fact: I had pretty good year in 2018-19

I had to give the law school an account of what I did last year. Turns out, I had a pretty good year:

I gave the University of Nebraska School of Law’s Roscoe Pound Lecture on March 27, 2019. My lecture was entitled “Corporate Governance in a Populist Era” and an article based on the lecture is forthcoming in the Nebraska Law Review.

I was the Keynote Speaker at the 55th Annual National Diocesan Attorney Association, which was held in Portland, Oregon, on April 28, 2019. My talk was entitled “The Catholic Church’s Unfinished Business: Enhanced Scrutiny.” Relatedly, I have published three essays in Public Discourse on the Catholic Church’s sexual abuse scandal and the reforms adopted by the Church: Understanding the Vatican’s New Rules on Sex Abuse (May 14, 2019), Lay Review with Teeth: What (Didn’t) Happen at the Vatican’s Sexual Abuse Summit (March 10, 2019), and Canon Law Should Be Changed to Make Catholic Bishops Accountable (December 18, 2018).

I served as a speaker or panelist at Conference Board Webcast on Outsourcing the Board (September 8, 2018), Federalist Society Webcast on Outsourcing the Board (September 10, 2018), Lowell Milken Institute for Business Law & Policy’s Conference on Outsourcing the Board (September 21, 2018), Post-Tenure Career Arc Panel, UCLA School of Law Faculty Retreat (November 29, 2018), Federalist Society’s Symposium on Revisiting Corporate Social Responsibility (January 25-27, 2019), Lowell Milken Institute for Business Law & Policy’s Roundtable on Executive Compensation (February 8, 2019), and UCLA School of Law Faculty Colloquium (April 8, 2019).

I moderated the Corporate Governance and Founder Control Panel at the Lowell Milken Institute for Law and Business Policy at the UCLA School of Law’s Conference on Law and Entrepreneurship in Silicon Beach on March 9, 2018.

Cambridge University Press published my book, Outsourcing the Board: How Board Service Providers Can Improve Corporate Governance, which I co-edited with University of Chicago Law School Michael J. Marks Professor of Law M. Todd Henderson. Relatedly, the Lowell Milken Institute for Business Law & Policy and The Conference Board co-sponsored a conference devoted to the book at the law school on September 21, 2018. The Business Lawyer published a symposium comprising papers presented at the conference, to which I contributed an article entitled Rethinking the Board of Directors: Getting Outside the Box (volume 74, no.2, pp. 285-296).

The Tenth edition of my case book Business Associations: Cases and Materials on Agency, Partnerships, and Corporations, which I co-edit with UCLA School of Law Richard C. Maxwell Distinguished Professor of Law Emeritus William A. Klein and Harvard Law School Mitsubishi Professor of Japanese Legal Studies J. Mark Ramseyer, was published by Foundation Press.

Cambridge University Press published a book Can Delaware be Dethroned? Evaluating Delaware’s Dominance of Corporate Law, which I co-edited with my UCLA School of Law colleagues Iman Anabtawi, Sung Hui Kim, and James Park. I contributed the Introduction and a chapter entitled Interest Group Analysis of Delaware Law: The Corporate Opportunity Doctrine as Case Study to the book.

My law review articles included invited contributions to two symposia: Equal Access to Information: The Fraud at the Heart of Texas Gulf Sulphur, 71 SMU L. Rev. 643 (2018); KokeshFootnote Three Notwithstanding: The Future of the Disgorgement Penalty in SEC Cases, 56 Wash. U. J.L. & Policy 17 (2018).

I contributed two chapters to books: The Parable of the Talents, in Research Handbook on Fiduciary Law 97 (Edward Elgar Publishing; D. Gordon Smith & Andrew S. Gold eds. 2018); The Board of Directors, in The Oxford Handbook of Corporate Law and Governance 275 (Oxford University Press; Jeffrey N. Gordon & Wolf-Georg Ronge eds. 2018).

My publications also included Conservative Critiques of Capitalism, American Affairs, Fall 2018, at 113.

I continue to serve as a Featured Expert Contributor for the Washington Legal Foundation’s Legal Pulse. My recent briefs for the Pulse include With Emulex Corp., Supreme Court Could Raise Bar for “Merger Tax” Securities Suits (January 22, 2019), California Corporate-Board Quota Law Unlikely to Survive a Constitutional Challenge (October 2, 2018), Supreme Court to Once Again Examine Limits of Rule 10b-5 Liability in October Term 2018 Case “Lorenzo v. SEC” (August 6, 2018), and Perpetual Dual Class Stock versus the SEC’s Dubious Raised Eyebrow Power (February 23, 2018).

Yours truly cited by Virginia Federal District Court re Whether Disgorgement is a Penalty

U.S. v. Bank, 2:17CR126, 2019 WL 2023734, at *4 (E.D. Va. May 8, 2019)

Kokesh has sparked a debate about whether district courts have the authority at all to impose disgorgement because the Supreme Court appeared to question such authority. See Kokesh, 137 S. Ct. at 1642 n.3 (stating that the court offered “[n]o opinion on whether courts possess authority to order disgorgement in SEC proceedings”); Donna M. Nagy, The Statutory Authority for Court-Ordered Disgorgement in SEC Enforcement Actions, 71 S.M.U. L. Rev. 896, 898 (2018) (explaining how, at oral argument for Kokesh, the Justices questioned the authority to order disgorgement and invited challenges to it by disclaiming, in a footnote of the opinion, that it was not deciding the issue). Those arguing there is no authority for disgorgement suggest that, now that disgorgement has been declared a penalty, it can no longer be within a district court's equitable authority because a court cannot impose penalties when acting in equity. See, e.g., Stephen M. Bainbridge, INSIDER TRADING: Kokesh Footnote Three Notwithstanding: The Future of the Disgorgement Penalty in SEC Cases, 56 Wash. U. J.L. & Pol'y 17, 21-22 (2018). Those arguing that there is authority posit that just because disgorgement is a penalty for one purpose does not mean it is a penalty for all purposes, and that Congress has expressly recognized a court's power to order disgorgement. See, e.g., Nagy, supra, at 901-903. In March of 2019, a bill was introduced in the Senate that would resolve this debate by amending 15 U.S.C. § 78u(d) to expressly grant district courts the authority to order disgorgement. Securities Fraud Enforcement and Investor Compensation Act of 2019, S.799, 116th Cong. (2019).

That said, a district court's authority to order disgorgement is not at issue here. Accordingly, the Court assumes, for the purposes of this motion only, that district courts necessarily have the authority to order disgorgement under the equitable authority granted to them by one of the statutes discussed above. See 15 U.S.C. §§ 77t(b), 77v(a), 78aa, 78u(d) (1).

The cited article is: Bainbridge, Stephen Mark, Kokesh Footnote 3 Notwithstanding: The Future of the Disgorgement Penalty in SEC Cases. 56 Washington University Journal of Law & Policy 17 (2018); UCLA School of Law, Law-Econ Research Paper No. 17-12. Available at SSRN: https://ssrn.com/abstract=2992719

Yours truly cited by Wisconsin Federal District Court re Rights of First Refusal

Dewey v. Bechthold, 18-CV-1739-JPS, 2019 WL 2193865, at *4 (E.D. Wis. May 21, 2019):

Although Wisconsin courts routinely uphold these types of provisions, some courts have held that rights-of-refusal should be narrowly construed. Frandsen v. Jensen-Sunquist Agency, Inc., 802 F.2d 941, 945–46 (7th Cir. 1986) (applying Wisconsin law and holding that a right-of-refusal is not triggered by a merger). Finally, it is worth noting that there is no legally mandated option price. Rather, the option price is set at the discretion of the corporation. See Nichols Constr. Corp. v. St. Clair, 708 F. Supp. 768, 771 (M.D. La. 1989), aff’d mem., 898 F.2d 150 (5th Cir. 1990) (holding that “the mere failure to pay ‘fair value’ for stock under a stock redemption agreement” is not “fraud or breach of fiduciary duty.”); F.B.I. Farms, Inc. v. Moore, 798 N.E.2d 440, 448 (Ind. 2003) (“to the extent that restriction devalues the shares in the hands of any individual shareholder by reason of lack of transferability, it is the result of the bargain they struck”); see also Stephen M. Bainbridge, Corporate Law, § 14.2 (3d ed. 2015) (explaining the aforesaid and noting that, where a right-of-refusal provision is in place, even option prices set at fair market value will be dramatically discounted by potential third party purchasers to account for the bargain’s low likelihood of success).

Bainbridge & Henderson's Outsourcing the Board in Quartz

Quartz published a long article on my book with Todd Henderson, Outsourcing the Board. Sadly, it's behind a paywall. But you can buy the book!

Video of my talk on corporate purpose in a populist era as the 2019 Pound Lecturer at University of Nebraska Law School

Link

Greetings from Lincoln, Nebraska, where I’ll be giving the Roscoe Pound Lecture

I’m honored to have been asked to give the University of Nebraska School of Law’s Roscoe Pound Lecture, which I’ll be doing tomorrow. My lecture is based on my paper, Corporate Purpose in a Populist Era.

Updated version of Restoring Confidence in the Roman Catholic Church: Corporate Governance Analogies

I have had an updated version of my article posted: Bainbridge, Stephen Mark, Restoring Confidence in the Roman Catholic Church: Corporate Governance Analogies. UCLA School of Law, Public Law Research Paper No. 18-32. Available at SSRN: https://ssrn.com/abstract=3249236 or http://dx.doi.org/10.2139/ssrn.3249236

Events of the Summer 2018 brought the long running sexual abuse crisis in the Roman Catholic Church back onto the front pages, highlighting the role of diocesan bishops in covering up the scandal and enabling abusers. In response to these developments, the Church is again considering reforms to protect victims and punish abusers and enablers. This article proposes that the Church create a system for laity to anonymously report allegations, enact strong protections for whistleblowers, and impose a mandatory whistleblowing requirement on priests. As a 2018 Pennsylvania grand jury report demonstrates, however, the laity was reporting the abuse to the Church but the hierarchy buried those reports in secret files. The ultimate problem thus is not so much the lack of reporting, as it was the lack of action after the report. Accordingly, the article’s principal proposal is the creation of both diocesan and national disciplinary bodies led by expert lay members as the ultimate authorities in sex abuse cases. The proposal draws an analogy between these bodies and corporate audit committees and argues that a number of aspects of how audit committees function can be usefully adapted to the proposed review bodies.

This version of the article has been revised to take into account developments at the February 2019 Vatican summit on the sex abuse scandal. Those developments do not change the recommendations made herein.

Keywords: Roman Catholic Church, corporate governance, compliance, law and economics, credence good

Looking back at 2018: My books, articles, monographs, columns, etc...published last year

Books

Outsourcing the Board: How Board Service Providers Can Improve Corporate Governance (Cambridge University Press 2018) (Coauthor: M. Todd Henderson)

Can Delaware Be Dethroned?: Evaluating Delaware's Dominance of Corporate Law (Cambridge University Press 2018) (Coeditors: Iman Anabtawi, Sung Hui Kim, and James Park)

Business Associations: Cases and Materials on Agency, Partnerships, LLCs, and Corporations , 10th Edition (Foundation Press 2018) (Co-editors: William A. Klein and J. Mark Ramseyer)

Articles and Book Chapters

Introduction, in Can Delaware Be Dethroned?: Evaluating Delaware's Dominance of Corporate Law (Cambridge University Press 2018)

Interest Group Analysis of Delaware Law: The Corporate Opportunity Doctrine as Case Study, in Can Delaware Be Dethroned?: Evaluating Delaware's Dominance of Corporate Law (Cambridge University Press 2018)

Conservative Critiques of Capitalism, American Affairs, Fall 2018, at 113

Parable of the Talents, in Research Handbook on Fiduciary Law 97 (Edward Elgar Publishing; D. Gordon Smith & Andrew S. Gold eds. 2018)

The Board of Directors, in The Oxford Handbook of Corporate Law and Governance 275 (Oxford University Press; Jeffrey N. Gordon & Wolf-Georg Ronge eds. 2018)

Kokesh Footnote Three Notwithstanding: The Future of the Disgorgement Penalty in SEC Cases, 56 Wash. U. J.L. & Policy 17 (2018)

Other

Perpetual Dual Class Stock versus the SEC’s Dubious Raised Eyebrow Power, The WLF Legal Pulse (February 23, 2018)

Supreme Court to Once Again Examine Limits of Rule 10b-5 Liability in October Term 2018 Case “Lorenzo v. SEC”,The WLF Legal Pulse (August 6, 2018)

California Corporate-Board Quota Law Unlikely to Survive a Constitutional Challenge, The WLF Legal Pulse (October 2, 2018)

Canon Law Should Be Changed to Make Catholic Bishops Accountable, Public Discourse (December 18, 2018)